Monday, 13 February 2017

WHO WILL PAY NOVA SCOTIA FOR UNUSED MARITIME LINK?

The
2041 Group, which included several capable lawyers, spent many a night
parsing the contracts which contained Nalcor’s commitment to Emera for the Nova
Scotia Block (that’s the free electricity). Then there’s another set that
commits one terawatt hour at a price set by auction at the New England bar.

The
group watched — in horror — as Nalcor openly backed itself into a corner as it
continued to spend tens of millions on the Muskrat Falls project knowing, as it
did, that the Federal Government had given veto power to Nova Scotia over award
of the Federal Loan Guarantee (FLG) — and thus project sanction.

By
the time Bruce Huskilson, Emera’s CEO, had finished shaking down Ed Martin, the
UARB — the equivalent of our PUB, acting on behalf of the Government of Nova Scotia— must have known Nalcor would agree to any demand to get sanction.

Nalcor’s
behavior has always contradicted the rules of common business practice, and of
common sense.

One
of Nalcor’s claims — about which I have always been skeptical — is its
assertion that there is no recourse for Emera with respect to a delay in providing
the electricity committed under the provisions of the Nova Scotia Block. Implicit
in the suggestion is that the $1.5 billion Maritime Link (ML) could be
completed two or more years in advance of Muskrat Falls’ electricity generation — without any obligation by Nalcor, the party responsible — to provide compensation
for the unused asset.

The
cost of servicing the ML debt, together with depreciation and other related
expenditures, is estimated at approximately $180 million per year.

In
2014, Nalcor stated: “There is no compensation associated with a delay. This is
addressed in the Energy and Capacity Agreement also available on the project
website. The commitment to provide energy to Nova Scotia starts with
commissioning of the third generating unit at Muskrat Falls and continues for
35 years from that event.”

This arrangement is out of character for a mature
company like Emera, which would be expected to protect their shareholders
against non-performance by another contracting entity. It is a fundamental principle of the law of
contracts. Evidently Emera believes that,
for its part, the shareholders are protected.

Recently, some clarity was provided to this
question by Nova Scotia’s UARB. That Board has instigated aHearing for April 10, 2017 and established a Preliminary Issues List in consequence of an action by Emera subsidiary Nova Scotia Power
(NSP). That company is seeking to recover the cost of delay to the Muskrat
Falls Generation Facility through the Nova Scotia ratepayers.The company is attempting to recover $162 million in 2018 and another $164 million in 2019.

Those costs have been included in the
application to the UARB (which can be found in the above link):

Emera plans to deliver the Maritime Link on
time and on budget. Nalcor has confirmed a delay of at least two years on the
dam.

In seeking this $326 million in payments
prior to delivery of the Nova Scotia Block, Emera argues that the Nova Scotia
ratepayer will see benefit with the early commissioning of the Maritime Link,
which justifies the early recovery. Emera
states:

“The Maritime
Link provides a strategic transformational opportunity for enhanced access to
competitive energy markets and should be made available for the benefit of Nova
Scotia customers immediately upon commissioning… With the completion of the
regional energy loop created by the Maritime Link, NS Power will be
well-positioned to access competitive energy markets in a manner not previously
possible to obtain value through the import (or export) of energy via the
Maritime Link.”

Early
commissioning of the Maritime Link may provide some value to Emera and the ratepayers of NS, but the company doesn’t circumscribe its claim — at least not yet —
and has seemingly set out to establish who will pay in any event. For that
reason, unless Nalcor completes the ML roughly simultaneously with completion of the Labrador Island Link — and deliver the 1000 GWH committed under the
Nova Scotia Block — we need to ask: who will pay this $326 million which Emera is
seeking?

One thing we can safely assume is that the
UARB won’t happily allow early recovery from the NS ratepayers, without delivery
of the Nova Scotia Block, of all the costs sought by Emera.

Unlike
the PUB of this province with respect to Muskrat, the UARB is empowered in Nova
Scotia to review all matters pertaining to the ML. The UARB has shown that it
will challenge Emera’s subsidiary, Nova Scotia Power, to the benefit of the NS
ratepayer. The Dunderdale Government
removed the PUB’s review of the Muskrat Falls project when it refused to
endorse the scheme. The Ball Administration has failed to give the Board a new
mandate regarding the project.

What
is likely to result from the UARB Hearings? One possibility is that the UARB will
compromise, allowing a partial recovery of the ML costs. Undoubtedly, linked
to any such decision will be the amount of energy, if any, which will be available from
Newfoundland and Labrador prior to completion of the ML.

(A
short primer: If Nalcor completes the LIL by the end of this year — Stan
Marshall having suggested that that’s the intention, even if some engineers believe he
is a bit optimistic — then Nalcor can use the roughly 80 mW of Recall power which
Hydro Quebec is currently selling for this province. Nalcor can also utilize
surplus power from Island-based hydro sites to help make up the difference. But
that power won’t be available during the high-demand winter months — except if
Nalcor runs Holyrood thermal or buys it from Hydro Quebec. The reader should
note that the Recall power is part of Nalcor’s current revenue stream — which
will be lost if it is given over to the Nova Scotia Block. Thermal energy from
Holyrood won’t be cheap. And power purchased from Hydro Quebec won’t be free,
either.)

The
question remains, if Nalcor fails to deliver any of the power it has committed
to NS, what does Emera do if the UARB does not approve the full $326 million
over 2 years? Who pays the shortfall?

It
is worth reading the language of the Maritime Link Joint Development Agreement.
Article 8 refers to the financing of the
project. Within this section it makes
reference to Emera’s ability to make an application to the UARB for recovery of
the Projected Overrun and applicable AFUDC. AFUDC accounts for the interest on the debt, and the return on equity
used during construction.

The question is this: do the
costs associated with Nalcor’s failure to supply the Nova Scotia Block
commensurate with the completion of the ML constitute a cost overrun?

Put a different way: With Emera
having made an application to adjust the UARB Approved Amount due to the
additional capital costs, and to the AFUDC during the delay, would the UARB
rejection or partial rejection of the cost make Nalcor exposed to the
“Unapproved Overrun plus any Financing Costs” as outlined above?

Lets face it: $326 million
is a lot of money. The NS ratepayer will
not want to pay it, Emera will not want to pay it, and Nalcor will not want to
pay it.

The language in the Martime
Link Joint Development does not afford a definitive conclusion. But the many references to Nalcor’s responsibility
for part of the capital and financing costs not approved by the UARB are a
cause for concern. From section 3.2:

In short, the Application before the UARB
raises many questions: What is the alternative source of power which could
squelch Emera’s claim to the UARB? If the available Recall is part of this
“solution”, which group of ratepayers — NS or NL — will have priority access to this
cheap energy? If the UARB declines Emera’s Application, does that company have
recourse to Nalcor for the additional costs, given the contract language shown
in the above Exhibit?

Nalcor could have an exposure here of several
hundred million dollars.

Likely Nalcor — as in the case of the Quebec Superior Court's decision on the Upper Churchill Renewal Agreement and how it impacts the Water Management Agreement — will offer the usual assurance that there is no problem here.

A better option is for the public to give some attention to the issue during, and following, the UARB Hearings. When it comes to transparency, Nalcor could learn a lot from that agency..
______________________________________________________________
Editor's Note: I want to acknowledge an unnamed professional and thank him for his important contribution to the preparation of this Post.

35 comments:

Just more incompetence and likely adds to the long list of deceit by Nalcor and Ed Martin to the public. Nalcor is likley tied up in legal knots that Stan Marshall insists there is no choice but finish the project , even if another 10 billion needed. There is really no end to this until we go bankrupt. And likely we will use our island generation and run short in winter forcing more oil burning at Holyrood. Likely still best to put Muskrat on ice and suffer the consequence fron Nova Scotia lawsuits.

I would think the Uncle shows some of the qualities of Christ in exposing corruption. Rather than hater, his courage and work seems to support the average Nflder and the poor will be stuck with this massive debt. The rich, Williams, Ed Martin and others are not concerned about double or more power rates, saying this was to happen anyway, as oil was going to 150 dollars a barrel or more. The the Board of Trade crew, all in favour of this project and debt, and consequent 20 percent unemployment rate coming, according to Wade Locke. And I bet not 5 percent of Nflders even know that it is not Muskrat Power going to Nova Scotia, but our island power that hard working Nflders has paid for since 1960, now to go to Nova Scotia free of charge. The unreliable Muskrat power is to feed Nfld island, not NS. There is a serious difference.

Given the OBVIOUS DECEIT from Nalcor and the COMPLETE lack of transparency... the public needs to DEMAND that the current Board resign, or be dismissed outright... AND that an inquiry begin IMMEDIATELY !!!

Why should we continue to let a group of uncooperative individuals who are tasked with serving the public simply lie, dodge questions, hide the facts AND continue to get paid richly for risking citizens lives through poisoning, drowning, suicides or literally freezing in their homes.

Exactly how much MORE absurd and/or tragic must this become before NL citizens' begin to show some of the the so-called "backbone" and bravery that we've shown in the past !!

It's time NOW for thousands (literally) to march directly into the HOA, via force if/as needed, and demand an inquiry into this corrupt fiasco that is stealing our childrens' futures as you read this.

The whole system is corrupt. First step is a new political party of competent people -- then a complete change of government. Unfortunately as things stand today, it wouldn't matter which of the three parties was in power. They are all corrupt.

Lol, we need a new political party like we need a second Muskrat Falls.Another bunch of NL politicians pounding their chests and telling everyone what they want to hear to get elected and then doing nothing when they get in. Once a NL politician gets one whiff of the trough of self benefit, political patronage and the many other perks and bribes that come their way they ALWAYS look after #1.I don't think my comment is cynical...just look at our pathetic record.

"Nalcor can use the roughly 80 MW of Recall power from HQ... can also utilize surplus power from Island-based hydro sites...... (Could) runs Holyrood thermal or buys it from HQ during high-demand winter months”

Excellent analysis, one that was not publicly done before.

If Nalcor ends up having to pay a sensible portion of that Emera $326 million shortfall (over 2 years), we may well be better off to just provide NS that whole 1000 GWH Block instead.

==> At least that power would then be removed from our 35 years commitment <==

The timing to procure such power is attractive as markets are relatively depressed, and one nearby utility has lots of surpluses...

Obviously, we need a detailed costs analysis to ensure the optimal scenario mix is picked. (Assuming the whole transmission loop is completed and performs

(I also agree with Robert when he says this link is NL's option to interconnect with the North American power grid - where surpluses exist)

So Nalcor do not have to pay damages to Emera, but if Emera can not get cost recovery from the UARB then Nalcor are on the hook for part of it? UG is right to say that this finally makes sense, as Emera most certainly would have wanted protection for Nalcor's delays. But now the question is if Nalcor needs to pay emera in excess of 100 million, where does the cash come from? Nalcor are so leveraged it will likely have to come from "equity" injections from their shareholder.

If this is indeed true there is just another reason to call for a full inquiry into this fiasco. 45 million in lawyers fees to arrive at these contracts...

Based upon the original estimates for this project the NS/NL deal sounded reasonable, 20% of the power for 20% of the cost approximately. I do recall that when the government changed in NS, they and the UARB went after an even better deal and apparently got it.Now that the project costs for the parties to the deal, NL and NS, has changed substantially and ignoring differences in depreciation, in very rough terms we will be paying approximately 12 billion/1.5 billion or at least 8 times more for the power than NS.The inequity in this deal is starting to look more and more like the royal shafting we got on the upper Churchill deal with Quebec.

Correction to the last post. Nova Scotia get 1000 GWhr or 20% for 35 years. In addition they get 250 GWhr for the first 5 years in exchange for the first cost overrun. then they are also garunteed access to another 1200 GWhr on average at market rates. So they will get more than 50% of the power, at a blended rate of about 7-9 cents per kwhr. Meanwhile in NL we have to start taking 40% then over time the full amount. We will start out paying about 55 cents per kwhr for the initial delivery.

Make no mistake Muskrat Falls is a great form of equalisation moving the wealth of one province (NL) to the benefit of others (NS and Que).

REmember Danny when your power bills double, as NS get access to cheap Newfoundland power.

Yeah, I think I had it right the first time because the 80% that we get we don't need in NL. It has to all be sold in NS and through NS at market rates, including maximizing the 300MW recall from the upper by using MF power in Labrador instead of CF recall. Eight times the cost is closer to it and if MF goes to 15 Billion then its 10 times.Peckford may have had it right when he cautioned Ms Dunderdale to be careful that all that flows downstream from CF is the water.

There is the saying ...Once a man , twice a child.We are today into what appears to be a major snow storm. A few days ago I read the Hydro Nov report listing their many upgrades for our island electrical system.......it was impressive, a lot of upgrades, no apparent concerns to meeting our peak demand, despite the Liberty warning that this winter will be touch and go, and the PUB calling for a urgent assessment of our situation for the next 3 years. I woke at 7 am to the sound of wind, we were into blizzard conditions here in Logy Bay. VOCM soon reported we were into a power alert, as one of Hydro gas turbines had shut down. The present load on our grid should not yet require the gas turbine, as temperatures outdoors is only minus 3.The main Holyrood units are the main thermal source for the Avalon. Likely they tried a start up of the gas turbine to test readiness and the startup failed. So much for their assurances.Schools and businesses are closed, and Metro Bus has stopped running. This Bus situation assures my daughter gets paid for staying home. She works for an accounting company, and then does this work at home, being unable to make it to the office.

As I child, growing up in Bishop`s Cove,Conception Bay, snowstorms were exciting and fun times. The temperatures were much colder. After a big storm the school would be closed for a week. One of our kitchen windows had no storm window, and the glass pane would be totally covered with patterns of leaves formed by the frost. The bottom of the pane would have frost a quarter inch thick, and my mother would scratch the frost with her finger nails. The house had no heat overnight, and firing up the stove was a chore I shared with my brother, and usually took 30 minutes to get things warm. We never worried much about power failures or stores not open. Our cellar held 3 tons of coal, and we had enough dried and cut and stored wood to fill a large storage room. The cellar also had 25 barrels of potatoes, and there was the barrel that held a 100 lbs of flour, and another barrel with 50 gallons of water. Once the storm passed, it was exciting to venture out and see some of our neighbours buried in. Not even a house and slide could get through. After 2 or 3 days, and no sign of the bulldozer, there would be men from Island Cove take matters into their own hands. Someone in Island Cove was sick,and needed to get to Spaniards Bay to the railway station, or to the doctor in Bay Roberts. A dozen or so men would shovel a path for the horse and slide. There would be places were there was little snow,and other places were the drifts were 5 or 6 feet high. This road to Spaniards Bay was 3 miles long. Eventually horse and slide transport was in operation, and the bells on the house was a pleasant sound. After another couple of days the bulldozer would arrive. It would often get stuck. Men would get big round logs and put in front of the dozer and the tracks would drag them under, and eventually propel it ahead to free itself. Sometimes this took hours to move a hundred feet. Some of the logs would be broken up. What fun to watch. And snow deep enough to let us dig tunnels. We often would shovel out Aunt Rachel, and the snow would form a archway to her house. The power typically failed, and the cozy lamps would be used at night, but which made reading difficult. I guess children usually don`t worry much, and today too, a lot of children are happy for the blizzard.Winston Adams, Logy Bay.

Yesterday on the weather station I realized that technically, here in Nfld, if it snows at all, we are more or less into a blizzard, by mainland standards. Environment Canada uses the three 4s method: the conditions requires winds of at least 40 kmh, a visibility of o.4 km, and a duration of 4 hours. This sounds like a wimpy mainland blizzard. Our winds here average 20 mph, so over 40 kmh on average, so if it snows at all, with visibility of .4 km, almost a quarter of a mile, then this is blizzard. Sounds like an alternative fact. According to the Airport Torbay data our winds hit blizzard condition at 9;30 pm last night, but visibility was 24 km. Visibility dropped to 0.4 km at about 7 am this morning. Winds was then 59km and gusting to 82, strong enough to wake me. After 4 hours we are now technically into a blizzard. Excited, I went online before breakfast, to see if our test house in Mount Pearl was still operating with the mini-split heat pumps, or if the blizzard would shut them down. The outdoor units are exposed to this snow and wind. And I have opinion from MUN experts that the performance of these units is mostly a MYTH. High humidity during snow storms, as well as the snow itself increase the frequency of the defrost cycles. At 4 am the relative humidity (RH) was 78 percent, by by 7am it was 88 percent, now just past 11am it is 93 percent (Torbay airport data) The units are showing this: one unit defrosting about every 4 hours, the other two were defrosting about 2 hour intervals but now at 1 hour intervals. These do not have wind guards or snow hoods , which would be beneficial to have, but few install them. At 5am all 3 units were using a combined total of 2.14 kw . This has increased slightly to 2.34 kw, due to the more frequent defrost cycles. Without the blizzard these would use 1.5 kw total at less himid conditions and at minus 3 C This house is 4000 sq ft, and the garage is also being heated.If the garage heat was turned off, the rest of the house is presently consuming 1.57kw for heat. For comparison, small 700 sq ft house in Nfld requires 4 to 5 kw for baseboard heat. If the power failed, a small 2000 watt generator could power these units to heat the whole 4000 sq ft house. Hopefully the power will not fail.Hopefully the heatpumps will not fail. They have now operated for 3 years, so I expect they will handle this blizzard, but who knows. I find this exciting to monitor this performance, especially since our power companies refuse to do prudent best practices: end-use research. Rather than encourage efficient heating systems, to reduce the power grid peak load, they ask we be ready to turn down our heat to avoid rotating outages. Or put on sweaters, and sit at home with a blanket cover, as promoted by their Take Charge TV ads! Who would think in 2017 there is a better way. We need not go back to the 1950s. What is fun for kids is not so funny for seniors.Winston Adams

The BLIZZARD......was a wimpy one. It barely met the classification,as visibility of 0.4 km lasted barely 4 hours, which ended at 2 pm. Sustained winds topped only at 64 km. Hardly of the class that took down the Ocean Ranger , when winds were 130 kw and snowplows could not operate. And the mini-splits heatpumps....not a problem today, By 3 pm with less defrosting the load dropped to just 1.75 kw. This house has 18 kw of baseboard connected, presently turned off. A 200 amp panel is presently using 7.3 amps for heat. This past spring, Nfld Power`s own energy consultant stated that these units were `Very Suitable` for Nfld and could save a huge amount of energy and also reduce peak demand,as many would continue to operate in our winter climate. This was ignored by Nfld Power. Meanwhile the Telegram`s James McLeod called this a `wicked blizzard`. At 9am the grid had a load of 1479 MW. In fact this is only the average that we had for last years month of January, and more than 200 MW less load than a recent cold snap this month. Hydro`s glowing report of readiness for winter conditions stated the relative reliability of our standby gas turbines: The two older units, after upgrades and repairs, are were 4 times less reliable than the recent addition last year, not surprising since the older units are some 40 years old. The Power Watch this morning to the public was due to `one of the gas turbines` being inoperable. Neither the Telegram nor CBC said more, expect the Telegram stated it was a loss of 120 MW. The new unit in fact is 123 MW,the older units 50 MW, so the new unit not the older ones now is inoperable! Seems it was intentional not to state this, given the contraversy that this 100 million unit was somewhat used and already 6 or 7 years old when purchased in a hurry following DARK NL, and likely no warranty. Transparency....as usual. The Blizzard part 2 is supposed to hit tonight.......stay tuned.WA

The Blizzard Part 2 had significint snow fall, but overnight and this morning was not technically a blizzard according to Torbay Airport weather data. Winds were modest, but visibility only saw o.4 km for 1 hour, and was generally 0.8km. Maybe that is why there was little power failure issues, except for the gas turbine that failed to start. For 100 million dollars every family in Nfld could have their own back up generator, some 150,000. If there were a few that failed to start, 99.9 percent would. It is not great when a 120MW new? gas turbine fails. It was never verified this this was a "marine duty" unit, meaning it is durable in a salty environment like we have here. The old units have suffered from this, as they don't wear out , but corrode on internal parts......but it is too soon for this being a problem for the recent addition. If this unit had been ordered before Dark NL, a marine duty would be prudent, as such an asset is expected to last 40 years. As to the heatpumps.......continued operation in stormy weather is very important. Our power companies usually see 2.8 hours of outage per year, which is not too bad. Can outdoor heatpumps match this or do better? A failure means then turning on baseboard heaters,so is not a critical thing. The house being monitored in Mount Pearl had no issue, now for 3 years. With just -1C , the humidity rose to 97 percent, causing frequent defrost, yet overnight the total load was less than 2 kw. Great performance. Can these be made storm proof? Yes. One unit mounted in the attic at another location has now run for 6 years .........fully protected from wind, snow , rain, sleet, or salt. And efficiency improves in this installation, as temperatures is often warmer and humidity lower. This should be done for all new houses, and is more difficult to do in existing houses, but not impossible. Reliability to operate under our severe weather and ability to reduce peak demand are reasons (excuses) stated why our power companies do not help customers with incentives for these, as other provinces do. It is a crock. Who can doubt that they do not want reduced revenue because customers save energy of 50 percent or more on heating. But after 30 years on the market, 6 months ago Nfld power acknowledged, in thier flyers, they can save energy. Isn't that progress!WA

Winston,My own Engineer's mind is directed more to the need to re-engineer existing building clusters, to get the best return on energy conservation measures.Consider MUN campus/Arctic Vessel complex. Definitely buildings considered functional for the next 50 years say, need to be upgraded to near LEED Silver, zero net energy targets. A big mistake when Arctic Vessel was built, was not linking heat transfer with the AquaArena, Health Sciences, residences, area commercial, etc. Renewable energy sources; geothermal, wind, solar, etc. seem to not have been considered, when setting up the Central Heating and Power Plant. Did they ever go the mile to consider power generation? Single family housing, spread amongst the outlying urban sprawl is not going to get the reduction in energy demand commencerate with current and future technologies.

Robert, agreed that institutional buildings give significant opportunities for saving on peak demand. However, single detached house here (160,000) with a avg load of 4 kw is 650MW on the grid . 50 percent reduction is 320 Mw at night, but somewhat less in evenings when lights etc displace some of the space heat load. For the larger house monitored we get: 18kw demand for several hours with baseboard recovering using programmable thermostats, 8.5 kw with baseboard on steady, and just 3.7 kw with minisplit on steady. That is 4.8 kw reduction at night.That is very significant is it not? And it little matters where the house is, whether urban or rural. And the cost is much less than net zero construction, and cost effective. Other provinces promote this for residential to get system demand reduction. WA

They would apparently be the big buildings users, and therefore on the hit list for Engineering upgrades, and diversion to renewable energy prospects. I tend to discount single family over sized residences, as important because; a) the Owners will decide for themselves what level of heating costs fits their disposable income, and lower income Owners don't have the money or means to take advantage of "smart" energy saving technologies.

Robert, I don't have those loads. But increased residential baseboard heat load growth was the primary reason stated for Muskrat.I doubt of there is any hit list for reducing loads.Based on the low estimate of Muskrat power available for the island and at 12 billion total cost , it is something like 1 million dollars for capacity to feed 18 kw to one house for the heat portion. Crazy is it not. So homeowners will mostly put in baseboard heat, unless the rate skyrockets, and agreed low income residents can't afford efficient systems without incentives......some middle class, and high income can afford and are doing it, but that is why incentives are mostly universal elsewhere. And the fact is, as contractors are not engineers, and have little guidelines, savings and demand reduction is only half or less than achievable for residential. Proper guidelines can make a big difference. About 50 units installed in 2010, 1000 in 2014 and 2000 or more in 2015, with high satisfaction rates,(nfld Power survey) despite units being undersized etc. 500 average houses should reduce peak a Megawatt......so it is adding up. 200 larger houses would save that. These incremental reductions add year by year.......that's what other jurisdiction do.....but of course for all buildings........housing is overlooked, maybe because it doesn't justify the usual engineering analysis, I suggest. Baseboard heaters are banned in some countries and was considered in NB, it is so inefficient.WA

About Des Sullivan

Uncle Gnarley is written by Des Sullivan, of St. John's.
He is a businessman engaged in real estate, retail and development companies.
A Director of Sullivan Capital Corporation, he is a former Executive Assistant to Premier's Frank D. Moores (1975-1979)and Brian Peckford (1979-1985).
He also served as a Part-Time Board Member on the Canada-Newfoundland Labrador Offshore Petroleum Board (C-NLOPB).
Uncle Gnarley permitted the use of his highly regarded name provided he could have full access to state his own rather unequivocable opinions. (A more detailed Profile of Uncle Gnarley is described in the very first Post entitled "Uncle Gnarley is alive and well" found on this site.
Sullivan is a firm advocate of sound fiscal management by the provincial government and intends to use this Site as a forum for commentary on the major issues of the day. Says Sullivan, "Newfoundland and Labrador inspires debate on a variety of issues, a veritable Muskrat Falls of opinion".
Readers are invited to leave their opinions, too.
Uncle Gnarley will post every Monday, and more often as events warrant.